July 17, 2013
I'm afraid that this proposal undermines the very intent of the JOBS act. There have been many good analyses, but this one is particularly worrying:
"... angels will no longer be able to self-certify their accredited status. Instead issuers will need to verify accredited status with safe harbor categories such as providing the issuer a copy of your W-2, tax filing, or brokerage statement or a third-party (attorney, accountant, or registered investment advisor) certifies that you are accredited....
"I don't know about you, but there is NO WAY I am going to give an entrepreneur any of these documents. Every angel I've talked with about the rules feels the same way....
"These requirements could kill angel investment."
I urge you to reject the extra, onerous requirements this proposal places on companies trying to raise money (especially startups trying to raise angel rounds).